All private organizations with at least fifty employees and some public organizations must set up a professional whistleblowing system by 01 January 2018 in accordance with Law no2016-1691 dated 09 December 2016 (Sapin II Law) and Decree No. 2017-564 dated 19 April 2017. The necessary system is very simple in its principles, but there are numerous requirements.

The FCA and PRA have issued a consultation paper proposing new requirements for certain larger financial institutions, while the new senior managers’ regime also impacts firms’ whistleblowing arrangements.